Andrew Tait English Partner, specialising in UK Gambling law
Remote customer interaction
The Gambling Commission has published a consultation for the remote sector to improve standards of Customer Interaction. This closes on 12 January 2021 after which there will be a further stage of consultation on the results and proposed changes, all to be completed by early February 2021, with implementation required some time in the Spring of 2021.
This builds on the existing social responsibility codes (3.4.1) and guidance stemming from July 2019 but imposes much more prescriptive requirements on 3 specific indicators of harm: playing beyond levels of affordability; individual vulnerability; and time spent gambling.
With regards to the first harm, the Commission is seeking to impose thresholds at which affordability assessments will need to be carried out. Whilst evidence will need to be collected and reviewed, the Commission in this consultation and in its Annual Enforcement Report (published on 6 November 2020) makes it clear that it should equate to average disposable income levels of circa £400 pm with further reduction to account for other leisure expenditures and Covid-19 impact. The Commission anticipates that operators will need to rely on third party providers, such as beBettor to help handle the volume of affordability checks needed.
Keep an eye out for our upcoming webinar in conjunction with beBettor and the Gibraltar Betting & Gaming Association focused on affordability requirements. Our panelists will discuss regulatory and technical aspects of affordability with a particular focus on practical solutions and Commission expectations.
To see the Gambling Commission’s consultation, please click here: https://consult.gamblingcommission.gov.uk/author/remote-customer-interaction-consultation-and-call/